Labelling and Composition of Meat Products Guidance Notes September 2003 Table of Contents Page Important Note 5 Legislation in the devolved assemblies 5 Section 1 – The European Definition of Meat 6 1. What is the European definition of meat? 6 2. What are the percentage limits on fat and connective tissue? 6 3. How is the new definition different from that previously in force in the UK? 6 4. How will the European definition be implemented and how will it work in 7 practice? 5. When does it come into force? 8 6. Do the percentage limits apply to each meat ingredient, or to all the meat 8 ingredients taken as a whole? 7. Can fat and connective tissue be added separately? 9 8. Will the European definition require recipes to be changed? 10 9. In what cases will the definition not apply? 10 10. What about mechanically recovered meat (MRM)? 11 Section 2 – The Meat Products Regulations 13 1. How do the new MPR differ from the old Regulations? 13 2. What is a meat product? 14 3. To what meat products do the Regulations apply? 14 4. Which parts of the carcase may not be used in uncooked meat products? 15 5. Reserved descriptions – General 15 6. How is meat content determined for the purposes of ensuring compliance 16 with the reserved descriptions? 7. What are the requirements relating to pies? 16 8. Have the requirements of the reserved descriptions changed? 17 9. Why does the minimum meat content differ depending on the species used? 17 10. Name of the food for certain meat products 18 11. How do these “name of the food” requirements relate to the Poultrymeat 19 Marketing Regulations? Section 3 – Labelling of Meat Products 20 1. Scope of QUID 20 2. How will QUID declarations work in practice? 21 3. What types of ingredients will need to be QUIDed? 21 4. QUID rules specific to meat products sold loose 23 2 5. How should the ingredient be described and quantified? 24 (i) Animal derived ingredients not covered by the definition of meat 24 (ii) “Specific cuts” 25 (iii) Dried or cooked meat ingredients 25 (iv) Compound ingredients 26 6. How is the QUID declaration calculated? 27 7. “weight of finished product” 27 8. “the ingoing ingredient” 27 9. How is the “declarable weight” determined? 29 10. How should the QUID declaration be presented? 30 11. What if the QUID declaration is more than 100%? 30 12. The list of ingredients – Description of excess fat and connective tissue 30 13. How should “bone-in” cuts be treated? 31 14. What are the rules relating to meat content claims (made in addition to 32 QUID)? Section 4 – Enforcement 33 1. Who is responsible for enforcing the requirements? 33 2. What is the penalty for non-compliance? 33 3. Do the requirements apply to foods intended for export? 33 Section 5 – Calculation of Meat Content 34 1. The “FSA method” 34 2. The CLITRAVI (Liaison Centre for the Meat Processing Industry in the EU) 35 method Annex A – The European definition of meat – Directive 2001/101/EC 36 Annex B – The FSA Method 37 Annex C – Table of typical values for meat ingredients 48 Annex D – Examples of meat content calculation – using the FSA method 51 Example 1 – Beefburger 51 Example 2 – Pork and Beef Sausage 53 Example 3 – Chicken Nuggets 56 Example 4 – Meat Pasty 58 Annex E – The CLITRAVI method 60 Annex F – The reserved descriptions – compositional requirements 63 Annex G –Validation of Methods for the Calculation of Meat Contents 67 Executive Summary 67 Conclusions and Recommendations 67 Annex G1- Calculated Meat Contents – Results 69 3 Annex G2 - Calculation Methods Used 70 Annex G3 - Sampling Principles and Practice 72 Annex G4 - Analytical Protocol 74 Annex G5 – Products, Recipes, and Results of Analysis 76 4 Important Note The aim of this guidance is to offer informal, non-statutory advice relating to the European definition of meat for labelling purposes (Directive 2001/101) as it relates to The Meat Products Regulations 2003 (MPR), and the provisions of the Food Labelling Regulations 1996 (FLR), and in particular Regulation 19 of the FLR on Quantitative Ingredient Declarations (QUID). Separate Agency Guidance is available on the general provisions of QUID. Every effort has been made to ensure that these guidance notes are as helpful as possible. However, it is ultimately the responsibility of individual businesses to ensure their compliance with the law. Businesses with specific queries may wish to seek the advice of their local enforcement agency, which will be the Trading Standards Department at the Local Authority. Legislation in the devolved assemblies Following the process of devolution, food legislation is now commonly made on a separate basis in England, Scotland, Wales and Northern Ireland. This is the case with the FLR, and MPR; there are four sets of each Regulation. Therefore the England Regulations apply only in England, the Scotland Regulations apply only in Scotland, and so on. However, the four sets of each Regulation differ only in the powers under which they are made, and the food authorities given responsibility for enforcement. The provisions relating to the composition and labelling of meat products will be similar in each of the four sets of Regulations. 5 SECTION 1 – THE EUROPEAN DEFINITION OF MEAT 1. What is the European definition of meat? Commission Directive 2001/101/EC was agreed in July 2001 and published in November 20011. It amends the Food Labelling Directive (2000/13/EC), and introduces a European generic definition of meat for the purposes of labelling. The definition puts meat ingredient declarations in meat products on the same basis throughout the European Union, and hence provides consumers with consistent and more transparent information. The Annex to the Directive (which provides the definition itself) is reproduced in Annex A to this Guidance. The new definition: § Restricts the generic term “meat” (as well as species names such as “beef”, “pork”, “chicken” etc.) to skeletal muscle with naturally included or adherent fat and connective tissue; § Introduces maximum numerical limits for associated fat and connective tissue, depending on the species of the meat. Any fat or connective tissue in excess of these limits cannot be counted towards the meat content and must be declared separately in the ingredients list (although a QUID declaration will not be required for this fat and connective tissue); § Excludes mechanically recovered meat (MRM), which must already be declared separately in the ingredients list. MRM may not be counted towards the “meat” content; and § Requires other parts of the carcase such as liver, kidney, heart etc to be labelled as such. The generic term “offal” may not be used. In addition, these parts of the carcase may not be counted towards the QUID declaration for any meat ingredient. 2. What are the percentage limits on fat and connective tissue? Species % Fat % Connective Tissue Pork 30 25 Birds and rabbits 15 10 All other red meats and mixtures 25 25 3. How is the new definition different from that previously in force in the UK? 1 OJ Reference L310, 28.11.01, p.19 6 The UK had a legal definition of meat. The definition was contained in the Meat Products and Spreadable Fish Products Regulations 1984 (MPSFPR) (replaced by the new Meat Products Regulations 2003). The MPSFPR were national provisions, and did not implement any European legislation. Meat was defined in the MPSFPR as “flesh including fat and skin, rind, gristle and sinew in amounts naturally associated with the flesh used”. Other parts of the carcase were also counted as meat. There were specific limits for fat in meat products based on a minimum lean meat content, which was defined as “lean meat free when raw of visible fat”. However, no limits were applied to skin or connective tissue other than through the requirement that they were “in amounts naturally associated”. § The European definition differs therefore by basing the definition only on skeletal muscle. As a result, certain parts of the carcase can no longer be regarded as meat (e.g., heart, tongue, liver, kidney, head meat etc.) § There are specific percentage limits on the amount of fat and collagen that may be counted, along with the skeletal muscle, as meat. 4. How will the European definition be implemented, and how will it work in practice? Implementation of the European definition is in two distinct parts, and is achieved by two separate Statutory Instruments (SI): (i) The Food Labelling (Amendment) Regulations 2003 These Regulations amend the FLR to implement the new definition, which now appears in Schedule 6. There are three effects of this amendment: § Where the word “meat” (or words such as “beef”, “pork”, “lamb”, “chicken” etc.) is used in a product’s list of ingredients, the ingredient in question must be “meat” within the meaning of the new definition. § Where a QUID declaration is given for an ingredient described in this way, the quantity declared must be calculated in terms of the new definition, and must therefore take account of the limits for fat and connective tissue. § Where an ingredient described in this way contains fat or connective tissue in excess of the limits in the definition, this excess must be declared separately in the product’s list of ingredients. (ii) The Meat Products Regulations 2003 These Regulations revoke and replace the Meat Products and Spreadable Fish Products Regulations 1984 (MPSFPR). The new Regulations carry forward some of the national provisions of the MPSFPR, while bringing them 7 in line with the new definition. The principal changes of the new Regulations are that: § The minima for the amount of meat products must contain in order to be described by the reserved descriptions are now expressed in terms of the new definition.